Case No. ZI-2018-359723-1

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TURBOFAC Commentary (188 words)

Notes:

Case No. ZI-2018-359723-1 is a relatively straightforward application of OFAC’s position that a dealing with a blocked government is not necessarily prohibited, even when high-ranking officials within that government (including the head of state) are designated as SDNs. In this case, the applicant U.S. person proposes “to sell solar power to the government of Zimbabwe.” OFAC concludes that the proposed transactions do not appear to be prohibited, but to “note that Emmerson Dambudzo Mnangagwa and others who are affiliated with former President Robert Mugabe continue to be designated pursuant to the Zimbabwean sanctions program.” As of the date of the application and the response, Emmerson Dambudzo Mnangagwa was the President of Zimbabwe.

In all likelihood, the applicant was concerned about basis on which one could claim that Emmerson Dambudzo Mnangagwa, as president of Zimbabwe, could benefit indirectly from the deal with the government...

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Case No. ZI-2018-359723-1

TURBOFAC Commentary (188 words)